Joint BoardRegulationsDec 30, 2016related by meaning
(a)(9) (9) Directly or indirectly attempting to influence, or offering or agreeing to attempt to influence, the official action of any officer or employee of the Internal Revenue Service by the use of threats, false accusations, duress or coercion, by the offer of any special inducement or promise of an advantage, or b…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
…e in willful tax evasion and with
determinations of willful civil tax fraud penalties under section
6663. See, e.g., Spies v. United States, 317 U.S. 492, 499
(1943). .
Indeed, in this case petitioner filed its corporate Federal
income tax returns for 1994 and 1995 without claiming deductions
for redemption dividends. …
IRCCourt RulingsAug 1, 2005related by meaning
his annuity policies. As
stated earlier, section 72(e)(5) applies to the surrender of an
annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a
distribution upon the complete surrender of an annuity contract
is includable in gross income to the exten…
IRCCourt RulingsDec 19, 1995
…x for failure to pay estimated
income tax), section 6662(a) (accuracy-related penalty), and
section 6663(a) (fraud penalty).
Second, structurally, section 72(t) is part of chapter 1 of
subtitle A of the Internal Revenue Code. Subtitle A is
denominated "Income Taxes" and chapter 1 is denominated "Normal
Taxes and Surtax…
IRCCourt RulingsDec 2, 2013related by meaning
ion 6662(a) and (b)(2) imposes an accuracy-related penalty equal to
20% of the amount of any underpayment of tax that is attributable to a substantial understatement of income tax. By definition, an understatement is the excess of
the tax required to be shown on the tax return over the tax actually shown on the
return.…
IRCCourt RulingsFeb 9, 1998
…lent, we consider the same elements that are considered in
imposing the fraud penalty under section 6663. Clayton v.
Commissioner
, 102 T.C. 632, 653 (1994). Fraud is an intentional
wrongdoing designed to evade tax known or believed to be owing.
Edelson v. Commissioner
, 829 F.2d 828, 833 (9th Cir. 1987), affg.
T.C. Me…
IRCCourt RulingsApr 3, 2002related by meaning
ules or
regulations.
6
Section 6662(a) provides that, if it is applicable
- 14 -
6
(...continued)
underpayment of tax may not exceed 20 percent of the underpayment, notwithstanding that the portion is attributable to
more than one of the types of misconduct described in sec.
6662(a). Sec. 1.6662-2(c), Income Tax Regs. …
IRCCourt RulingsAug 16, 2005related by meaning
ted
penalty pursuant to section 6662(a) with respect to the
underpayment attributable to the unreported 10-percent additional
tax under section 72(t). Section 6662(a) imposes a 20-percent penalty on the portion
of any underpayment attributable to any of various factors, one
of which is negligence or disregard of rules …
IRCCourt RulingsJan 11, 2012related by meaning
al authority unde section 6664.
See Rule 142(a);.Higbee v. Commissioner, supra at 446-447.
Respondent has met the burden of production by showing that petitioners improperly deducted or failed to rëport $1.4 million
contributed to the Millennium Plan and used the funds to purchase
assets for the primary benefit of Mr. …
IRCCourt RulingsMar 19, 2025related by meaning
applies, w e sustain respondent’s determination that petitioner
owes the additional tax under section 72(t)(1) for 2021 .
IV. Section 6662(a) Penalty Section 6662(a) and (b)(2) impose s an accuracy-related penalty
equal to 20% of the portion of an underpayment of tax required to be
shown on a return that is attributab…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
IRCCourt RulingsMar 12, 2015related by meaning
as
either unable to pay the tax or would suffer an undue hardship if he or she paid on
the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this
issue because he failed to introduce into evidence the substitute for return that he
purportedly…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
IRCCourt RulingsJun 17, 1997related by meaning
ederal income tax. See sec.
6662(b)(2). As relevant herein, section 6662(a) imposes an
accuracy-related penalty equal to 20 percent of an underpayment that is due to a substantial understatement of income tax. In
the case of a corporation, a substantial understatement exists if
its income tax was understated by the gre…
IRCRegulationsDec 19, 2016related by meaning
(a)(1)(iii) (iii) Section 6049(a)(1), relating to information returns with respect to payments of interest aggregating $10 or more in a calendar year, in effect with respect to payments made after December 31, 1962, and the regulations under such section, within the time prescribed for filing such statement (determined…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsSep 24, 2002related by meaning
titioner is not
liable for the sec. 6662 penalty.
3
S.K. apparently stands for Smoothie King, which we gather
was the trade name of a product.
OPINION DAWSON, Judge
: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(3) and
Rules 180, 181, and 182.
1
The Court agrees with and…